Open Ocean Aquaculture

The Project:

Hawaii Ocean Technology’s (HOT) has been granted a Conservation District Use Application for its ahi aquaculture project. They plan to use 247 acres off the north Kohala coast of the island of Hawaii to hold 12 orb-like cages for growing tuna for export outside of Hawai’i.

Read why ten eminent scientists recommend against instituting aquaculture fisheries in the Gulf of Mexico

The Problems:

  • Fish Farming promotes the proliferation of antibiotic-resistant bacteria, which can infect humans.
    The industrialization of aquaculture has resulted in many of the same environmental and human health problems currently created by livestock factory farms. In addition to polluting aquatic ecosystems with the enormous volume of waste produced by the fish they confine, aquaculture facilities threaten the environment and human health by releasing hazardous substances such as pesticides, antibiotics, and other drugs into the aquatic environment.

    HOT fails to elaborate on potential health issues that may occur when thousands of fish are confined in a small space. Often, industrial aquaculture facilities address this problem by utilizing the same irresponsible antibiotics practices as industrial livestock operations; rather than reducing the density of fish, fish farms continuously administer sub- therapeutic doses of antibiotics. This promotes the proliferation of antibiotic-resistant bacteria, which can infect humans.  The problem is exacerbated by cages and net pens allowing antibiotics and antibiotic-resistant bacteria to pass freely into surrounding waters.

  • Farmed Fish Strip the ocean of fish for their feed
    HOT states a 100 pound tuna requires approximately 200 pounds of dry feed. One thousand tons of feed stock per month will be required when fully operational by 2013 yet they admit that the specific components of fish meal and fish oil to be used as feed is at present unknown.
  • Farmed Fish Breed Disease which is passed on to wild fish
    The risk of disease transmission is increased when imported, unprocessed fish are used as feed therefore it is imperative to disclose what the components of this feed will be. Further, when feed accumulates on the seafloor, it is eventually decomposed by bacteria, which consume oxygen dissolved in the water and can thus create hypoxic “dead zones” below aquaculture facilities.
  • Waste—The Hawaii County Department of Research and Development states that the project could generate as much as 2,000 tons of “offal” yearly and asks for details in how it would be handled (page 13). HOT replies (page 14) that “no waste will be introduced into the Big Island landflls.” Where will it go? There is a suggestion that ranchers may be interested in the byproducts. Will that pass Department of Health muster?
  • Lease cost—Two existing aquaculture operations in Hawaii pay combined yearly lease revenue to the state of $3500 (Hukilau/Cates= $1400; Kona Blue= $2100). What percentage of $120 million expected yearly revenues will HOT pay the state for exclusive use of 247 acres of ocean resources?
  • Noise—No acoustic impact analysis report has been prepared to indicate what combined effects noises in the 70-130 decibel range (page 7) would have on marine mammals.
  • Cage fouling—It is unclear how algal fouling would be cleared from the cages (page 9). Would it be accomplished by divers tediously scrubbing the cages on a daily basis, or by raising the tops of the cages to the surface to “air dry” them for hours, as is done regularly by Kona Blue?
  • Mortalities—Percentage of dead fish to be removed from cages is estimated at 1% (of 20,000/cage). How is this estimate arrived upon, since this species has not been raised previously in Hawaiian waters? What percentage of “morts” would be tested for disease? How would 2400 dead fish (with possibility of disease) be disposed of? Landfill? Incinerator?
  • Size and scope—What is the purpose of proposing such an enormous project despite, “a multitude of untried and untested aspects of this project?” (DAR, page 21-22). Other aquaculture ventures in Hawaii have proceeded with conservative size and project scopes, yet HOT proposes a lease area three times larger, with production scaled at 10-20 times more than Hukilau/Cates and Kona Blue. Why? HOT continues to be vague on the expected yields of their project, by a factor of 100%! They contradict earlier statements of 6,000 ton (12,000,000 pounds) yearly production by stating (page 35) that production will vary between 6,000 or 12,000 tons, “depending upon the final system design.” That is an incredible amount of uncertainty and wiggle room. One obvious discrepancy in their stated impacts is it would then require twice as much fish feed (24,000,000 pounds) yearly for the greater yield.
  • Public Trust Doctrine and Precautionary Principle—Food & Water Watch cited Hawaii Constitutional provisions in their August 27, 2009 letter (page 38). These seem every bit as relevant to the review of the applications being sought as any other laws and rules cited in the submittal, yet neither HOT nor staff responded to indicate they were being considered or incorporated in any way.
  • Engine design/Hybrid Solar Ocean thermal Energy Conversion Power—The propulsion system originally described in the DEIS subsequently changed by the time the FEIS was issued, thereby denying the public the opportunity to study its potential impacts. Staff notes that HOT submitted the design to them on 9/9/09, meaning the public has not seen it within the framework of legal environmental review, except for in this submittal, only made available to the public four days ago.
  • Disease—There is no discussion of how potential disease outbreaks in the cages would be handled. A full mitigation plan must be discussed. Spread of disease, pathogens, and parasites are major negative impacts that have devastated caged and wild populations of fish globally, and is one of the most dangerous side-affects of well-intended aquaculture projects. See attached scientific studies by Gaughan, Frazer (UH), and Tacon & Metian. All three studies, and an attached article about the 85% collapse of Chilean aquaculture stocks, describe catastrophic impacts spread by fish farms.
  • Fish food
    It is acknowledged that the enormous amount of food to supply such a large biomass of pelagic fish as proposed will undoubtedly have impacts on the area where it is collected, grown, and/or processed. Studies indicate that harvesting millions of tons of baitfish (sardines, herring, anchovies, menhaden, krill, etc.) worldwide greatly impacts regional ecosystems and competes with wild fish populations’ ability to feed themselves (see: Tacon & Metian).

    Therefore, aquaculture operators are continually seeking substitutes to feed their caged stock. Kona Blue has substituted soy protein and chicken trimmings to offset percentages of fish meal and fish oil. Top level piscatavores (fish eaters) like ahi are not expected to have the same growth characteristics as wild fish if they are fed land-based proteins. HOT acknowledges they, “have not identified the best diet yet.” (page 44).

    HOT gives a cut and paste answer throughout the submittal that includes these quotes: “HOT will use a feed company which is responsive to our exact specifications, and very transparent about their feed ingredients and processing. At this time the vendor to supply the fish feed has not been selected. So, the specific components of the fish meal, fish oil is currently unknown. HOT has no plans to use GMO soy. HOT will also seek to identify local alternatives…” (page 35 et al).

    Considering they are projecting the need for 12,000,000 pounds of feed annually, this language is incredibly vague. There must be full disclosure and understanding of the components of the fish feed, the sources from which they are derived, and the impacts from withdrawing them and importing those resources to Hawaii. Note that 100% of the feed would be imported.

    On the same page, HOT claims, “No soy or grains of any kind are expected [emphasis added] to be used as part of the feed. Ahi are carnivorous (meat eaters) not herbivores (vegetable eaters) and the company intends to use a fish feed that contains components consistent with the usual Ahi diet and nutritional profile.” That seems to indicate they would be using 100% ocean-based food, which again brings up questions about cumulative impacts on bait fish stocks. and needs to be clarified and conditioned.

    Finally, how much space would be needed to store these enormous amounts of feed? Is there existing facilities in Kawaihae harbor to facilitate this/ How would vermin be kept from moving in and contaminating the feed?

  • Sustainability
    HOT repeatedly uses the term, “economically sustainable,” which presumably means they hope to have revenues exceed expenses and be financially successful. But it does not address using local resources to create benefits for local people, without depending upon imports and exports to balance the equation. 100% imports and 90% exports does not equal sustainability.
  • Economics
    For a proposal projecting such huge revenues, there is a shockingly small number of jobs expected to be created. Half of these are for divers and laborers. Furthermore, qualifying for Act 221 high tech tax benefits means that a large chunk of state revenues would be avoided. Detailed analysis of expected revenues through taxes and revenues should be disclosed.

Exceptional comments/quotations from the submittal document

Farm the ocean like we farm the land.” (page 16) The problem with this idealized notion is that this is not a farm; it is an industrial feedlot. As such, problems are similar to factory feedlots for cattle, chickens, or pigs—pollution, pathogens, disease, and the need for antibiotics.

Marine aquaculture has been well tested, is sustainable, and will create a better product.” (page 19) For those who may believe in this Pollyanna-ish view, I strongly suggest they read the book, “Swimming in Circles.” (Molyneaux)

The fisherman (sic) of the world can become farmers.” (page 20) (see above)

In other words, fish poop may be good for the oceans.” (page 35) How much?

Commercial output is still a long way away.” (HOT-page 40) Then why the rush to approve this enormous project while questions remain unanswered?

Staff notes the proposed project seems to be more science fiction than reality.” (page 57) It seems unwise to base real permit approvals on so many uncertainties.


Address all unanswered questions, economic, scientific, cultural and environmental concerns and inconsistencies through further research, dialogue, and outreach. Assure the vested rights of Big Island residents to have a bona fide voice in the process by scheduling meetings in West Hawaii. Be certain of the ability to mitigate potential problems and impacts before approving permits to allow the proposal to move forward. As Eden Peart of the Hawaii Farmers Union stated (page 33), “The proposal should not be considered without educational outreach and public hearings.”

Merely to cite ocean fishery mismanagement and plummeting populations of fish species worldwide to justify open ocean industrialized fish feedlots to be constructed is an impetuous approach. Great caution must be taken as we move to create better models for local food production. It is entirely possible that there is greater merit and much more potential for sustainability in reviving historic Hawaiian coastal fishponds, or in pursuing land-based recirculating aquaculture and aquaponics systems that utilize nutrient-rich fish waste to grow vegetables.

HOT submittal to State of Hawai’i

Tacon & Metian—2008 study—global overview on the use of fish meal and fish oil in industrially produced aquafeeds: Trends and future prospects

Gaughan—Spread of viral outbreaks and pathogens in baitfish, mollusks, salmon, tuna, and shrimp aquaculture operations

Gulf Aqua—Ten eminent scientists’ letter to U.S. Dept. of Commerce recommending against instituting aquaculture fisheries in the Gulf of Mexico (Aug. 2009).

Two Maui streams restored

After years of essentially being drained dry and left for dead, two legendary streams on the Hawaiian island of Maui came back to life this week, thanks to the work of Earthjustice.

The streams were diverted over a hundred years ago to irrigate sugar cane and pineapple plantations. Over time sugar and pineapple have faded in the islands, succumbing to cheaper foreign competition. This freed up the water to restore the streams.

But the old plantation companies have other ideas. They want to develop the farmlands and bank and sell the diverted stream water. To them the water is the key to cashing in with McMansions, condos, resorts, and shopping centers, all fueled by “free” stream water.

On the other side, Native Hawaiian and local communities have waited to restore the streams and the interconnected wetland taro patches that produce a staple food as old as Hawaiian civilization. Earthjustice attorneys took the case to the state water commission and won a ruling that some of the stream water must be restored. The ruling didn’t begin to go far enough and has been appealed to the courts. But it marked the beginning of the end of the plantations’ water monopoly. The commission ordered the restoration of some flows to Waihe’e River and Waiehu Stream, two of the four major waters in Central Maui.

When the fateful day came, the plantation diverters allowed some of the water to once again take its natural course. Every year brief downpours of heavy rains would temporarily make the streams flow again which helped retain the original streambed. Now, in the middle of summer, fresh clean water from West Maui’s mountains once again flowed to the sea breathing life into the plants and animals along the way. For the first time in more than a century, and after six years of legal battles, the community saw the streams come back to life.

The restored water recalled a similar water battle fought by Earthjustice 15 years prior on the island of O’ahu. In that case, native streams were eventually restored by court order after plantations stopped using it on cane and pineapples. And on O’ahu, as on Maui, the powers that be fought stream restoration tooth and nail. They tried as hard as they could to bank the water for, surprise! – development on former farmlands.

On Maui, the plantation companies are not going quietly. They have so far refused to provide all the water they were ordered to restore. One company is even resorting to scorched earth tactics, allowing some residents with priority water rights who had been receiving water though the plantation ditch system to be cut off, and refusing to cooperate to find a solution. The truth is the plantation companies easily have more than enough water to both restore the streams and supply these residents. Earthjustice will stay at it until these problems are addressed. In the courts and in the community, we will not rest until justice, and the waters of Maui rivers and streams, flow once again for present and future generations.

Visit Earthjustice’s Restore Stream Flow webpage to view a photo slideshow of the restoration of Waihe`e River and Waiehu Stream, and to learn more about this issue.

Biofuel Links

Massacres and Paramilitary Land Seizures Behind the Biofuel Revolution
Armed groups in Colombia are driving peasants off their land to make way for plantations of palm oil, a biofuel that is being promoted as an environmentally friendly source of energy…

U.N.: Not so fast with ethanol, other biofuels
Unchecked growth could see new problems offset climate gains, report says. “Unless new policies are enacted to protect threatened lands, secure socially acceptable land use, and steer bioenergy development in a sustainable direction overall, the environmental and social damage could in some cases outweigh the benefits,”

Scientists warn on biofuels as palm oil price jumps
Biofuels are likely to speed up global warming as they are encouraging farmers to burn tropical forests that have absorbed a large portion of greenhouse gases, climate scientists warned. The specialists, who gathered for an international conference in Hong Kong, rang the alarm bell as Malaysian palm oil futures prices hit all-time highs this week, helped by new demand for the vegetable oil from the biodiesel sector. “Some of these alternative energy schemes, such as biofuels, are truly dangerous,” said James Lovelock, an independent scientist known for the Gaia theory.


By Rene Umberger
This article was originally featured in the Sierra Club Newsletter of September 2009

Increasingly snorkelers and divers in Hawaii are asking “Where have all the fish gone?” Reef fish decline can be attributed to several factors, however none weigh so heavily as the losses due to extraction, including collecting reef animals for the home tanks of hobby aquarists.

According to the U.S. Coral Reef Task Force, “Severe overfishing for the aquarium trade occurs even in the United States. Aquarium fish species have declined by 59% over the last 20 years in Hawaii…Aquarium fishes outside of reserves experience significant declines – from 14% to 97%.”

The fish collected are Hawaii’s most beautiful, unusual and often rarest species. Given that the “marine ornamental” trade operates with few species limits and no limits on the number of fish they may collect, nor on the numbers of permits issued, it’s no wonder reef fish populations are in serious decline.

Hawaii has the highest rate of endemism for warm-water fishes, worldwide. These rare and beautiful species are highly prized by aquarium hobbyists and in fact, 45 percent of Hawaii’s top 20 collected species are endemic. As such, there is no replacement pool to draw from if they are over collected to the point where they cannot rebound, so these unique species could be lost forever. Each example of the sacrifice and waste associated with the aquarium industry diminishes our reefs and ultimately begs moral questions. In 2007, Hawaii’s collectors reported that of the 700,000-plus animals collected, 20,340 animals died before being sold (the true numbers are estimated to be several times higher). Putting 20,340 fish in perspective, it equates roughly to every fish on a reef the size of five football fields.

Half of Hawaii’s 20 most collected species are listed by aquarium experts as “unsuitable for captivity.” The most egregious examples of fish sacrificed for brief entertainment in a tank are the coral-eating butterflyfish, the Moorish Idol and the Hawaiian cleaner

wrasse; all known to starve within weeks because their preferred foods are not available in captivity. Additionally, collecting cleaner wrasses is especially harmful to the reefs; their removal reduces overall fish diversity and abundance quickly in the areas they’re taken from.

Mortalities continue throughout their journey from wholesalers to retailers and finally to hobbyists. Many will die shortly after arriving on the mainland from the stress of being starved, drugged and bagged for shipping, and the rest will succumb because they are almost impossible to keep outside their native reef habitat. Bob Fenner, a well-respected, 40-year veteran of the aquarium industry, wrote, “It is my estimate that even given sustainable collection practices . . . less than one percent live more than a year in captivity.”

Four-fifths of all collected species are herbivores, affecting the reef’s algae/coral balance, and most are Yellow tangs. Recent research in Hawaii shows that Yellow tangs are long-lived, surviving on reefs for decades; the oldest found so far is 41. Collected in Hawaii by the hundreds of thousands annually, suppliers consider them easy to care for and good for beginners, but only a few thousand of them will live beyond a year. The aquarium trade claims the losses are worth it: hobbyists cite their tanks’ “educational value” and industry professionals cite the need for livestock to support their lucrative “dry goods” sales of tanks, filters and lights. Common sense says reef animals are fueling a disposable hobby: When the fish die, they are thrown out and replaced, like cut flowers.

If you believe Hawaii’s reefs can no longer support the luxury trade in reef animals for a hobby, then visit our web site to sign the petition and learn more: For questions or to join our “Take Action” mailing list, contact Rene directly at Rene is a scuba instructor, underwater tour guide, member of the Maui Nui Marine Resource Council and is a member of the Sierra Club.

Letter Opposing Open Ocean Aquaculture Signed by 10 Scientists

August 3, 2009
Secretary Gary Locke
U. S. Department of Commerce
14th Street and Constitution Ave. N. W.
Washington, DC 20230

Delivered via e-mail to Jess Beck, Southeast Regional Office, NMFS at; and posted electronically to the Federal eRulemaking Portal at

Re: Proposed Rule 0648-AS65: Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico

Dear Secretary Locke:

Thank you for the opportunity to provide a scientific perspective on the environmental risks of open ocean aquaculture to help inform the Department of Commerce’s pending decision to approve or reject the Gulf of Mexico Aquaculture Fisheries Management Plan (FMP). We are a diverse group of academic scientists with experience in marine ecology, aquaculture, and fisheries who have published extensively in the peer-reviewed scientific literature. We identify a range of environmental risks of marine aquaculture, many of which should be addressed at an ecosystem scale to ensure that aquaculture ameliorates, rather than exacerbates, pressure on the oceans. We conclude that a coordinated, ecosystem-based regulatory approach, operating at the national level, is necessary to achieve a sustainable future for open ocean aquaculture in the United States. Without this approach, the piecemeal development of a marine aquaculture industry could result in significant and potentially irreversible environmental consequences. For this reason, we recommend that the Gulf of Mexico Aquaculture FMP should be disapproved.

There are six environmental risks of open ocean aquaculture that are most relevant to decisions about how the United States might proceed with this relatively new method of farming seafood. They are:

  1. Use of marine resources, 
  2. Risks of escaped fish to wild fish and associated ecosystems, 
  3. Nutrient, chemical, and habitat impacts, 
  4. Risk of disease and parasite amplification and retransmission, 
  5. Impacts of drug and chemical use, and 
  6. Impacts on predators and other wildlife. 

Use of Marine Resources
Aquafeed for many of the “carnivorous” species likely to be farmed in open ocean environments (e.g. cod, halibut, seabass, striped bass, yellowtail, and yellowfin tuna) contains very high percentages of fishmeal and fish oil (Tacon and Metian 2008). Average estimates of the ratio of wild fish required to produce farmed fish are 2.2 for “marine fish” and ~5.0 for salmon (Tacon and Metian 2008, Naylor et al. 2009). The wild forage fishes caught for aquafeeds play important ecosystem roles as food sources for higher trophic-level marine predators (Cury et al. 2000, Worm et al. 2006, Alder et al. 2008). As aquaculture has grown dramatically over the past two decades, the total demand for fishmeal and fish oil for use in aquaculture feeds has similarly expanded while the supply has remained relatively constant, thus increasing aquaculture’s share of global fishmeal and fish oil use (Tacon et al. 2006, Tacon and Metian 2008, FAO 2009, Naylor et al. 2009). Additional global growth in industrial fish production has the potential to undermine marine food webs by redirecting food sources away from those wild species most dependent on them (Pauly et al. 2002, Pauly et al. 2005, Karpouzi et al. 2007).

These facts all point to the use of marine resources as a key constraint in a sustainable future for aquaculture. Severing the reliance of fish farming on wild fish requires efficiency improvements at the farm level as well as a regulatory structure that sets overarching sustainability requirements for the industry as a whole, as most of the forage fish used for aquaculture are caught outside of U.S. waters (FAO 2009). Minimizing the use of forage fish in feeds and creating incentives for substitutes for wild-caught fishmeal and fish oil (including seafood processing byproducts, terrestrial plants, animal byproducts, single cell proteins and oils, and marine and terrestrial invertebrates) are needed if these feed sources are to be widely adopted by the aquaculture industry (Naylor et al. 2009).

Risks of Escaped Fish to Wild Fish and Associated Ecosystems
Aquaculture is known to be a major vector for exotic species introduction (Carlton 1992, Carlton 2001), causing concern over the ecological impacts that escaped farmed species can have on wild fish and the environment, whether the farmed species are native or exotic to the area in which they are farmed (Volpe et al. 2000, Naylor et al. 2001, Youngson et al. 2001, Myrick 2002, Weber 2003). Farmed salmon are known to regularly escape from net pen systems, negatively impacting wild salmon stocks by increasing competition for food and breeding sites, as well as reducing the fitness of wild fish through interbreeding (Einum and Fleming 1997, Youngson and Verspoor 1998, Volpe and Anholt 1999, Fleming et al. 2000, Volpe et al. 2000, Jacobsen and Hansen 2001, Volpe et al. 2001, McGinnity et al. 2003, Naylor et al. 2005, Hindar et al. 2006). As compared to salmon aquaculture facilities, which are generally sited in sheltered bays, net-pen systems in open ocean environments face increased risk of failure due to increased exposure to storms and stronger currents.

Developing separate broodstock to allow for selection of desirable growth characteristics is a hallmark of traditional agriculture and livestock production. To date, this has been common practice in aquaculture as well. However, allowing these practices to continue for aquaculture in open ocean environments, where fish will inevitably escape, greatly increases the risk to natural ecosystems of genetically-distinct farmed fish, even if these fish are native to the farming area. If the U.S. is to prevent environmental damage related to fish escapes, explicit regulations for broodstock maintenance and fish escape standards are needed that account for both individual farm-level effects and the cumulative impact of escapes occurring across a large number of farms. In the absence of these regulatory safeguards, permitting open ocean aquaculture in the Gulf of Mexico at this time risks significant harm to the environment and should not be allowed.

Nutrient and Habitat Impacts
Wastes, both dissolved and particulate, from open net pen systems are released untreated directly into nearby bodies of water and can have large impacts on the surrounding environment (Gowen et al. 1990, Beveridge 1996, Costa-Pierce 1996). More than half of the total nitrogen and phosphorus fed to fish in commercial farms is released into the surrounding environment (Beveridge 1996, Fernandez-Jover et al. 2007). In Japan, intensive culturing of finfish and its consequent generation of organic wastes has adversely affected the surrounding environment via deoxygenation (Hirata et al. 1994), outgassing of hydrogen sulfide (Tsutsumi 1991), and blooms of harmful plankton (Yokoyama 2003, Nakamura et al. 1998).

While proponents of offshore aquaculture frequently cite deep water and high flushing rates as reasons for low concern over nutrient pollution in these habitats, emerging science suggests this may be unjustified. A detailed study of a commercial-scale open ocean aquaculture facility in Hawaii found striking changes in benthic species diversity and community structure under and nearby submerged sea cages despite relatively deep water and high current velocity (Lee et al. 2006). High-resolution models of waste transport from aquaculture pens indicate that dissolved nutrients (from excess feed as well as fish excretion) do not disperse as rapidly and as uniformly as was previously assumed (Venayagamoorthy et al. 2009). This evidence suggests that the adage of “dilution is the solution” is not the appropriate framework under which to expand open ocean aquaculture in the U.S., especially in areas such as the Gulf of Mexico which are already under severe nutrient stress. To adequately address the cumulative impacts of nutrient input from multiple aquaculture facilities, aquaculture must be regulated and managed at the ecosystem level, not by relying solely on local-scale, individual permitting decisions such as those allowed by the Gulf of Mexico aquaculture FMP.

Risk of Disease and Parasite Amplification and Retransmission from Farmed Fish to Wild Fish
It is well known that intensive fish culture, particularly of non-native species, has been involved in the introduction and/or amplification of pathogens and disease in wild fish populations (Hastein and Linstad 1991, Nese and Enger 1993, Kent 1994, Nylund et al. 1994, Bakke and Harris 1998, Blazer and LaPatra 2002). In recent years, the issue of amplification and retransmission has received much attention because of the dramatic consequences of the spread of parasitic sea lice from salmon farms to wild salmon (Tully and Whelan 1993; Costelloe et al. 1996; Grimnes and Jakobsen 1996; Gargan 2000; Bjorn et al. 2001; Heuch and Mo 2001; Bjorn and Finstad 2002; Butler 2002; Morton et al. 2004; McKibben and Hay 2004; Penston et al. 2004; Krkosek et al. 2005, 2006, 2007; Morton et al. 2005). Disease outbreaks in other fish grown in open net pens appear to be common as well. For example, yellowtail farmed in the Mediterranean, Japan, and New Zealand have suffered substantial mortalities from monogenean parasites (Whittington et al. 2001; Hutson et al. 2007).

Of the six major environmental risks of open ocean aquaculture, disease is the one for which ecosystem-level management is most critical. Disease at the farm level is a husbandry issue, but it is the transfer of diseases from farm to farm and back to the wild that poses the largest environmental risks. Chile’s experience with Infectious Salmon Anemia in farmed salmon (Mardones et al. 2009, Vike et al. 2009) is a cautionary tale. Farm-level management led to numerous salmon farms being sited too closely together. Only after the salmon industry was decimated by the spread of this disease did Chilean authorities take the first steps toward breaking the disease cycle by developing “neighborhoods” to limit both farm-level and regional fish production (Intrafish 2009). If the U.S. is to prevent these types of disease dynamics, it must develop an ecosystem-based approach to aquaculture management that plans for expansion within an explicitly spatial context. As such an approach does not currently exist, approving the Gulf of Mexico aquaculture FMP risks significant harm not only to the environment, but to the aquaculture industry itself.

Impacts of Drug and Chemical Use
Most aquaculture operations use a variety of chemicals, including antifoulants, pesticides, and antibiotics (Tacon and Forster 2000), which can have negative effects on marine ecosystems or human health. Copper-containing paints, commonly-used antifoulants in the aquaculture industry, are toxic to many marine organisms, including seaweeds, mollusks, and Atlantic cod embryos (Andersson and Kautsky 1996, Granmo et al. 2002, Braithwaite and McEvoy 2004). Use of antibiotics has been shown to result in bacterial resistance in some aquaculture environments and to influence antibiotic resistance in humans (Kerry et al. 1996, Sapkota et al. 2008). Pesticides whose residues are known to be harmful to other marine life (Abgrall et al. 2000, Grant 2002) are sometimes used to control sea lice levels on farmed salmon (Roth 2000). In order to minimize the deleterious effects these chemicals have on the marine environment, their responsible use in aquaculture must be regulated by national agencies under a coordinated plan.

Impacts on Predator Populations
Expansion of open ocean aquaculture in the U.S. may also pose environmental risks to predators and other wildlife. In coastal salmon farming, a range of techniques, including the use of predator nets and underwater acoustic deterrent devices, are commonly used to reduce the impact of predators on stocks of farmed fish. These techniques, while generally successful at reducing losses of farmed fish, can have dramatic unintended consequences for the predators themselves, including alteration of natural behavior and the entanglement and subsequent drowning of large numbers of these air-breathing mammals (Morton and Symonds 2002, Wursig and Gailey 2002, CBC News 2007).

In open ocean environments, little is known about the potential impacts of fish farms on predators and other wildlife, but experience with farmed salmon suggests this will be an important concern. Limited evidence suggests that sharks and other large pelagic predators are attracted to submerged net pens (Galaz and de Maddalena 2004, NOAA 2005) and that predators that have become habituated to the presence of net pens, and hence a threat to human safety, have been killed (Lucas 2006). Should this practice become commonplace as the U.S. industry expands, this could put already vulnerable shark populations (Stevens et al. 2000, Baum et al. 2003, Myers and Worm 2005, Camhi et al. 2009) at further risk. Finally, submerged net pens and their associated mooring lines could pose entanglement risks to whales and other cetaceans, whose migration routes or foraging behavior bring them in close proximity to fish farms (Upton et al. 2007). Mitigating the effects of a young and growing aquaculture industry on predators and wildlife will require additional research on the interaction of farms and marine wildlife as well as the population consequences of the cumulative impact of those interactions.

A Final Note on Cumulative Impacts of Multiple Aquaculture Facilities

When the impacts of a single aquaculture operation are considered in isolation, they may be considered to be relatively mild. However, as the aquaculture industry grows, and should facilities be sited in close proximity to one another for economies of scale, the effects of their combined impacts may be greater than the sum of their individual impacts. This can be the case with nutrients, as well as with disease transfer, impacts of escapes, use of marine resources, and impacts on predators. To avoid these cumulative impacts and help avoid or ameliorate many of the risks discussed above, the precautionary approach should be a central tenet of the planning, management and permitting of aquaculture facilities.

Due to the scientifically documented, serious risks of offshore marine aquaculture outlined in this letter, we conclude it is critical for the U.S. to develop a consistent, precautionary set of environmental standards and implement regulations designed to protect the nation’s federal marine waters. In their absence, the development of a marine aquaculture industry in a piecemeal fashion, such as through approval of the Gulf of Mexico aquaculture FMP, could result in significant and potentially irreversible environmental consequences, including water pollution from waste products and chemicals, threats of disease transmission to wild fish populations, harmful effects on native marine species from escaped farmed fish, and ecosystem impacts of the increasing use of wild forage fish for aquaculture feeds.

Thank you for the opportunity to provide this scientific analysis on the ecological risks of marine finfish farming to help inform your decisions on how the U.S. should address this important issue. We conclude that an ecosystem approach to aquaculture management is critical to the long-term future of a sustainable domestic offshore aquaculture industry and incompatible with approval of the Gulf of Mexico aquaculture FMP at this time.


Rosamond L. Naylor, Ph.D.
Professor, Environmental Earth System Science
Stanford University

Felicia C. Coleman, Ph.D.
Florida State University Coastal & Marine Laboratory

Ian A. Fleming, Ph.D.
Professor, Ocean Sciences Centre
Memorial University of Newfoundland

L. Neil Frazer, Ph.D.
Professor, School of Ocean and Earth Science and Technology
University of Hawaii at Manoa

Les Kaufman, Ph.D.
Professor, Biology
Boston University Marine Program

Jeffrey R. Koseff, Ph.D
Professor, Civil and Environmental Engineering
Stanford University

John Ogden, Ph.D.
Director, Florida Institute of Oceanography
University of South Florida

Laura Petes, Ph.D.
Postdoctoral Associate
Florida State University Coastal & Marine Laboratory

Amy R. Sapkota, Ph.D., MPH
Assistant Professor, Maryland Institute for Applied Environmental Health
University of Maryland College Park, School of Public Health

Les Watling, Ph.D.
Professor, Department of Zoology
University of Hawaii at Manoa



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Karpouzi, V. S., Watson, R., & Pauly, D. (2007). Mdelling and mapping resource overlap between seabirds and fisheries on a global scale. Marine Ecology Progress Series , 343:87-99.

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Krkosek, M., Lewis, M. A., & Volpe, J. P. (2005). Transmission dynamics of parasitic sea lice from farm to wild salmon. Proceedings of the Royal Society B , 272:689-696.

Krkosek, M., Morton, A., Lewis, M. A., Frazer, N., & Volpe, J. P. (2006). Epizootics of wild fish induced by farm fish. Procedings of the National Academy of Sciences , 103:15506-15510.

Lee, H. W., Bailey-Brock, J. H., & McGurr, M. M. (2006). Temporal changes in the polychaete infaunal community surrounding a Hawaiian mariculture operation. Marine Ecology Progress Series , 307:175-185.

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Mardones, F. O., Perez, A. M., & Carpenter, T. E. (2009). Epidemiologic investigation of the re-emergence of infectious salmon anemia virus in Chile. Diseases of Aquatic Organisms , 84:105-114.

McGinnity, P., Prodohl, P., Ferguson, K., Hynes, R., O’Maoileidigh, N., Baker, N., et al. (2003). Fitness reduction and potential extinction of wild populations of Atlantic salmon, Salmo salar, as a result of interactions with escaped farm salmon. Proceedings of the Royal Society of London B , 270:2443-2450.

McKibben, M. A., & Hay, D. W. (2004). Distributions of planktonic sea lice larvae in the intertidal zone in Loch Torridon, Western Scotland in relation to salmon farm production cycles. Aquaculture Research , 35:742-750.

Morton, A. B., & Symonds, H. K. (2002). Displacement of Orcinus orca by high amplitude sound in British Columbia. ICES Journal of Marine Science , 59:71-80.

Morton, A., Routledge, R., Peet, C., & Ladwig, A. (2004). Sea lice infection rates on juvenile pink and chum salmon in the nearshore marine environment of British Columbia. Canadian Journal of Fisheries and Aquatic Science , 61:147-157.

Morton, M., Routledge, R. D., & Williams, R. (2005). Temporal patterns of sea louse infestation on wild Pacific salmon in relation to the fallowing of Atlantic salmon farms. North American Journal of Fisheries Management , 25:811-821.

Myers, R. A., & Worm, B. (2005). Extinction, survival or recovery of large predatory fishes. Philosophical Transactions of the Royal Society B , 360:13-20.

Myrick, C. A. (2002). Ecological impacts of escaped organisms. In J. R. Tomasso, Aquaculture and the Environment in the United States (pp. 225-245). Baton Rouge, LA: U.S. Aquaculture Society, A Chapter of the World Aquaculture Society.

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Naylor, R., Hindar, K., Fleming, I., Goldburg, R., Williams, S., Volpe, J., et al. (2005). Fugitive salmon: assessing the risks of escaped fish from net-pen aquaculture. BioScience , 55:427-437.

Naylor, R., Williams, S., & Strong, D. R. (2001). Aquaculture – a gateway for exotic species. Science , 294:1655-1656.

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Penston, M. J., McKibben, M. A., Hay, D. W., & Gillibrand, P. A. (2004). Observations on open-water densities of sea lice larvae in Loch Sheildaig, Western Scotland. Aquaculture Research , 35:793-805.

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Sapkota, A., Sapkota, A. R., Kucharski, M., Burke, J., McKenzie, S., Walker, P., et al. (2008). Aquaculture practices and potential human health risks: current knowledge and future priorities. Environment International, 34:1215-1226.

Stevens, J. D., Bonfil, R., Dulvy, N. K., & Walker, P. A. (2000). The effects of fishing on sharks, rays, and chimaeras, and the implications of marine ecosystems. ICES Journal of Marince Science , 57:476-494.

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Honokowai Restoration Project

The& Honokowai Cultural Overlay stabilization project is a component of Ka`anapali 2020, which includes restoration and preservation of an ancient farming archeological site, as well as a Multi-Cultural Center. The project is supported by businesses, organizations and the people of Maui. Steady progress is being made at the work site.


In October 2002, the Hawaii State Archaeological Society, with more than 20 archaeologists, inspected the project. They all felt Honokowai sites were among the best projects currently in the state. Many of them wanted to work with the Overlay team. They pointed out possible burials, house sites, trails, auwai, heiaus, shelters, and were interested in the land court award names.


The Multi-Cultural Committee extends its appreciation for the help received from Alexander & Baldwin to purchase tools; Ken Ota of Irrigation Systems, Inc. for 1600 feet of two-inch polyethylene waterlines; Jan Dapitan of Community Work Day for irrigation lines, valves, transportation; 14 Americorps workers for five days; and James Carpio of Jay’s Nursery for flat bed truck transportation and agricultural supplies.


The community is encouraged to participate in this special place. Families, children and elders are always welcome. Bring lunch, water, gloves, hand tools, hats and repellent.


Honokowai Archaeological Cleanup Project volunteers welcome every Saturday. Meet at 9am at the “Sugar Cane Train” parking lot off Honoapiilani Hwy, turn mauka at Pu’ukoli’i St. (north of Ka’anapali).Clean Archaeological sites an12/18/05dsey at 572-8085.



The Hawai`i Superferry presents a classic case of how not to do business in Hawai`i. Superferry’s lack of planning and violation of the Hawaii Environmental Protection Act has created a public debacle, inconvenienced their customers, and put Hawaii’s environment at risk. Three years ago the Sierra Club, Maui Tomorrow, and Kahului Harbor Coalition asked the Hawai`i Superferry and the Lingle Administration to complete an environmental review of the Superferry. Unknown environmental risks, concerned neighbor island communities, and a clear reading of the law demanded it. The review would have occurred while other planning proceeded. The Administration and Superferry corporation, however, decided to gamble and chose to skip this mandatory environmental disclosure process.

A unanimous Supreme Court decision – announced just hours after oral argument– called their bluff. Then, despite the decision from Hawaii’s highest court, Superferry decided to roll the dice again and start service early. Again, they lost when a judge ordered them to cease service to Maui.

A responsible company doesn’t allow a problem to get to the point where they receive a restraining order. They lost in court, lost neighbor island support, and lost credibility.

Poor planning and lack of community involvement angered some Kaua`i residents to the point of taking justice into their own hands, risking arrest (or their lives) to block the arrival of the Superferry. The Sierra Club does not condone lawbreaking – neither by the Superferry nor by the protesters. The protests, however, surely reflect the deep sense of injustice many neighbor islanders feel toward the Superferry – contempt that has been irresponsibly inflamed by proceeding in open disregard of the law.

This is why the public review process is so important in the first place: to understand the environmental tradeoffs, to involve the affected communities, to separate fact from fiction, and to protect the environment against unintended consequences. Unintended conssequences like the spread of mongoose to Kaua`i. Or the disastrous varroa bee mite to Maui. Or coqui frogs everywhere. These pests can easily become stowaways underneath car or truck bodies or inside the bushels of produce being transported. And with the Superferry shuttling hundreds of private vehicles and farm trucks daily, spreading these pests is all but guaranteed – unless proper protections are put in place and funded. For neighbor island farmers, the cost of new invasive species brought by the Superferry could be their livelihood.

The high-speed vessel operation itself may pose a threat to the marine mammals. Traveling at 35 knots through known whale calving areas may make riders sick in more ways than one. Environmental reviews are used to fix problems before they occur. They don’t just look at wildlife but at social consequences such as unbearable traffic, curtailment of traditional Hawaiian activities, and costly freight increases to small businesses. What are the best ways to minimize harm to Hawaii’s unique environment and communities? That’s what we’ll learn with an environmental review. Ultimately, the review process produces a better outcome for all involved, island-style.

When public taxpayer dollars are used as they are with the Superferry, the public has a right to ask questions – and get answers. Otherwise we might all be taken for a ride.

The environmental review process is a routine procedure. Private companies and State and Federal agencies complete reviews all the time. The Department of Transportation (DOT) has completed numerous such reviews in the past year. New roads, harbor improvements, airport upgrades: they all go through the process. Significantly, the DOT even required and conducted a full environmental impact statement when a ferry system just on the Island of O`ahu was proposed.

Three decades ago when the Hawai`i Environmental Protection Act was enacted, State elected leaders made clear that the environmental review be a “condition precedent” to implementation of the proposed action. In other words, the study must be complete before the project starts. We must look before we leap. It’s not only common sense, it’s the law.

Yes, the review process can be messy because you have to deal with real science – not soundbites and promises – and real public input. Superferry would actually have to respond to questions in writing and publish the answers. Yes, it takes a few months to complete. But the resulting document provides clear answers on what the adverse impacts are expected – and how best to prepare for them.

So why did the Superferry and the Administration chose to skip this process three years ago? Why did they chose not to complete an environmental review after the community groups asked, after neighbor island lawmakers asked, after the Maui, Kaua`i, and Big Island county councils asked, even after the State’s own Environmental Council ruled that it was required. Why not? Were they worried about disclosing something the public wouldn’t like to hear?

Hawai`i is like no other place on Earth, with hundreds of species found nowhere else on the planet and deep community values. To protect this uniqueness, the Sierra Club, Maui Tomorrow and Kahului Harbor Coalition requested Superferry and the DOT to comply with our keystone environmental law years ago. They chose to ignore the law. Our position hasn’t changed: if the Superferry is going to operate in Hawaii’s waters, it must to be done right. The first step is to comply with our state laws.

Superferry Facts and Myths

Refuting the Myths:  Hawaii  Superferry
by Ron Sturtz, President of Maui Tomorrow Foundation, Inc

Many people have asked that I provide a factual overview of the potential environmental impacts of the Hawaii Superferry, and the status of current legal challenges.  I hope that the following facts – in response to a few well-intentioned and passionate, but misinformed letters, editorials and news reports – will be helpful to the discussion.

Myth:  The State and Federal Courts have ruled that an Environmental Impact Statement (EIS) is not necessary:

 Fact: To quote Attorney General Mark Bennett in a published interview on February 6 by KGMB-9 TV:  “No court has ruled against the argument that an EIS was required in this case.”

Myth: All legal challenges are behind the Superferry.

 Facts: The Maui Circuit Court has granted legal standing to Maui Tomorrow Foundation, Inc., the County of Maui, and the Kahului Harbor Coalition to seek an EIS encompassing the entire Kahului Harbor and all its users, including the Hawaii Superferry. This case is ongoing and the parties are in negotiation. An earlier case which challenged the exemption from an EIS, given to the Hawaii Superferry by the Department of Transportation, has been appealed to The Hawaii Supreme Court. This action followed an initial ruling that Maui Tomorrow did not have legal standing in the case, and that the exemption could stand. That case is still open and an EIS may still be required.

Myth:  That this is an “11th Hour” claim by environmentalists seeking to stop the Superferry.

Facts: The public requested an EIS as early as the PUC hearing of November 19, 2004. Efforts to mediate disagreements over legal requirements of addressing environmental impacts led to litigation on March 21, 2005. There has been plenty of time – well over two years – for the Superferry to conduct an EIS.

The goal of an EIS is to study and address the potentially harmful economic, social and environmental impacts of the Superferry, and not to run it aground. The Maui, Hawaii, and Kauai County Councils all passed resolutions last year to require an EIS. The Maui County Council also directed County Attorneys to join in the current lawsuit against the State. Testifiers and sign-holding protesters on Maui have included a broad coalition of harbor workers, farmers, canoe paddlers, construction workers, residents from all parts of the island, as well as state and local governmental representatives.

Myth: The Hawaii Superferry is no more dangerous to whales than other vessels and ferries that regularly travel in oceans around the world, including Alaska, where humpback whales spend their summers. The Superferry’s Whale Avoidance Policy will adequately address potential collisions.

 Facts: Hawaii has never seen a vessel like this twin hull, 350 foot craft, traveling at speeds up to 40 knots. Just last month, a cruise ship in Alaska was fined $750,000 for killing a pregnant humpback whale, while traveling at a speed estimated at only 17-20 knots. The much-touted Whale Avoidance Policy (WAP) promised use of “forward looking sonar”, however it wasn’t ever installed in the vessel, and isn’t deemed practical. Their reduced speed of 25 knots is almost double the NOAA recommended safe speed of 13 knots. Furthermore, the Sanctuary Advisory Council, which adopted the WAP, is chaired by Terry O Halloran, HSF’s hired spokesperson. This represents a clear conflict of interest.

Myth:  Law enforcement and agricultural inspections will be stringent, and will stop the spread of drugs and invasive species.

Facts:  The time allotted for vehicle inspection will be insufficient to conduct adequate security and agricultural screening, due to the sheer numbers of vehicles loading and off-loading the giant ferry. 250 cars loading in 15 minutes leaves 3.6 seconds to thoroughly inspect each vehicle. With even 6 inspectors, that leaves 21.6 seconds per car.

Myth: The Hawaii Superferry is being unfairly singled out when nobody else has been required to due an EIS .

Facts: The last time a ferry was proposed, an EIS was required by the State. In 1988, the Oahu Intra-island Ferry System proposed to set sail. It, too, proposed the use of State lands and State funds. On January 19, 1989, the State DOT director Edward Y. Hirata prepared a 561 page Final Environmental Impact Statement that was directed to the Governor’s office for consideration. And that EIS didn’t even have to deal with inter-island issues of invasive species and sailing through whale-laden waters. That Ferry proposal had far fewer environmental challenges facing it, and yet, the DOT saw fit to prepare an EIS for the State Governor.

Myth: The State will incur millions of dollars in penalties if an EIS in required.

Facts: The Operating Agreement between the DOT and the Super Ferry, dated September 7, 2005, clearly protects the State from all damages for delays caused by an EIS.

Conclusion: Public discourse is valuable. It is helpful to remove the emotions and myths from the discussion, and focus on the facts. They speak for themselves.  Mahalo for letting me share mymana`o.

Ron Sturtz is the President of Maui Tomorrow Foundation, Inc, a non—profit organization committed to protecting Maui’s future through wise land planning, responsible growth, and environmental protection.